WorldLII Home | Databases | WorldLII | Search | Feedback

EPIC Alert

You are here:  WorldLII >> Databases >> EPIC Alert >> 2014 >> [2014] EPICAlert 21

Database Search | Name Search | Recent Articles | Noteup | LawCite | Help

EPIC Alert 21.20 [2014] EPICAlert 21

EPIC Alert 21.20

======================================================================= E P I C A l e r t ======================================================================= Volume 21.20 October 29, 2014 ----------------------------------------------------------------------- Published by the Electronic Privacy Information Center (EPIC) Washington, DC "Defend Privacy. Support EPIC." ========================================================================= Table of Contents ========================================================================= [1] Obama Issues Executive Order to Strengthen Consumer Privacy [2] EPIC Urges Transportation Department to Protect Driver Privacy [3] EPIC Recommends Research on 'Privacy Enhancing Technologies' [4] EPIC, 49 Other Organizations Urge Obama to Update FOIA [5] EPIC Spotlight: Domestic Drones, Surveillance and Privacy Risks [6] News in Brief [7] EPIC in the News [8] EPIC Bookstore [9] Upcoming Conferences and Events TAKE ACTION: Rock the Freedom of Information Act with FOIA.ROCKS! VISIT EPIC's New FOIA Domain: TWEET in Support of FOIA: #FOIAat40 LEARN about EPIC's FOIA Work: SUPPORT EPIC: ========================================================================= [1] Obama Issues Executive Order to Strengthen Consumer Privacy ========================================================================= President Obama has signed an Executive Order called "Improving the Security of Consumer Financial Transactions." The Order will mandate enhanced security features for government financial transactions, and require that "executive departments and agencies (agencies) shall, as soon as possible, transition payment processing terminals and credit, debit, and other payment cards to employ enhanced security features, including chip-and-PIN technology," which has greatly reduced financial fraud and identity crimes in Europe. The White House also made public a series of measures to safeguard consumer financial security. The Federal Trade Commission will be responsible for implementing, a website providing "a new one-stop resource for victims" of identity theft. The National Security Council Staff, Office of Science and Technology Policy and Office of Management and Budget must present the President with a plan in the next 18 months ensuring that personal data digitally released by the government to citizens is authenticated multiple times "so that every citizen's personal information is protected by the most secure methods possible." The Executive Order also supports "algorithmic transparency." In a related announcement of a summit on cybersecurity and consumer protection, the White House stated, "The Summit will bring together major stakeholders on consumer financial protection issues to discuss how all members of our financial system can work together to further protect American consumers and their financial data, now and in the future," the White House says, further stating that "The President will also renew his call to Congress to enact overdue cybersecurity legislation that will help protect Americans - particularly by clarifying companies' obligations when sensitive data is breached." EPIC has endorsed many of the proposals set forth in the Executive Order. In 2011 testimony before the US House Committee on Financial Services, EPIC president Marc Rotenberg suggested the use of "authentication by consumer-set passwords instead of biographic identifiers like date of birth or social security number; audit trails that record all instances where a customer's record is accessed; encryption of stored data; notice to the affected individuals and the relevant agency when there is a security breach; and limiting data retention by either deleting call records after they are no longer needed or divorcing identification data from the transactional data." EPIC has similarly advocated for algorithmic transparency. In EPIC's April 2014 comments to the Office of Science and Technology Policy on the privacy threats inherent in "Big Data," EPIC noted, "Because Big Data has threatened individual privacy for many years, and the risks to Americans increase daily, it is imperative that this Administration confronts Big Data problems expeditiously. Among the changes that are needed, the law should be updated to guarantee algorithmic transparency." Mr. Rotenberg also called for algorithmic transparency before the OECD at the October 2014 Global Forum for the Knowledge Economy in Tokyo. The White House: EO on Consumer Financial Transactions (Oct. 17, 2014) The White House: Fact Sheet on Executive Order (Oct. 17, 2014) EPIC: Comments on "Big Data and the Future of Privacy" (Apr. 4, 2014) EPIC: Testimony before US House on Data Protection (Sep. 14, 2011) EPIC: Congressional Testimony on Consumer Data Privacy (Jun. 15, 2011) ======================================================================== [2] EPIC Urges Transportation Department to Protect Driver Privacy ======================================================================== EPIC has submitted comments to the National Highway Traffic Safety Administration, a component of the US Transportation Department, urging the agency to protect driver privacy for "vehicle-to-vehicle" (V2V) technology, which transmits data between vehicles to prevent impending crashes. EPIC's comments highlight several privacy and security risks in current V2V technology, particularly the systems' ability to "access, consume, create, enrich, direct, and share digital information between businesses, people, organization, infrastructures, and things," thus "'set[ting] the stage for extraordinarily targeted monitoring and manipulation [of individuals].'" NHTSA is in the initial stages of mandating V2V technology. In August 2014, the National Highway Traffic Safety Administration issued an Advance Notice of Proposed Rulemaking and a research report on V2V. The report acknowledged that "privacy considerations are critical to the analysis underlying NHTSA's decision about whether and, if so, how to proceed with V2V research or regulation." EPIC's comments urged NHTSA to "complete a more detailed privacy and security assessment of V2V communications" and to: "(1) not collect [Personally Identifiable Information] without the express, written authorization of the vehicle owner; (2) ensure that no data will be stored either locally or remotely; (3) require end-to-end encryption of V2V communications; (4) require end-to-end anonymity; and (5) require auto manufacturers to adhere to the Consumer Privacy Bill of Rights," a framework for consumer privacy released by the Obama White House in 2012. In 2013, EPIC, joined by a coalition of consumer privacy organizations and members of the public, urged NHTSA to protect driver privacy and establish similar privacy safeguards for automobile "black boxes." EPIC: Comments to NHTSA on V2V Technology (Oct. 20, 2014) NHTSA: Report on V2V Technology (Aug. 2014) NHTSA: Advance Notice of Proposed Rulemaking (Aug. 20, 2014) EPIC: Automobile Event Data Recorders (Black Boxes) and Privacy ========================================================================= [3] EPIC Recommends Research on 'Privacy Enhancing Technologies' ========================================================================= EPIC has submitted comments to the National Coordination Office for Networking and Information Technology Research and Development following a September 2014 request for information on a National Privacy Research Strategy. EPIC's comments recommend research on Privacy Enhancing Technologies, or PETs, that "minimize or eliminate the collection of personally identifiable information." The comments further express support for Fair Information Practices and the White House's Consumer Privacy Bill of Rights. NITRD sought public input on "privacy objectives," "assessment capabilities," a "multi-disciplinary approach" to "both strengthen privacy and support innovation," and "privacy architectures." EPIC's comments point to a number of PETs that the agency can use to reduce or eliminate the collection of Personally Identifiable Information. Among these PETs are implementing differential privacy protections, improving anonymization, providing audit trails of how data is used, and creating standards for both reviewing and providing transparency when using predictive algorithms. EPIC also encouraged NITRD to implement a privacy-preserving architecture based on the Fair Information Practices, or FIPS. EPIC stated that the Obama White House's 2012 Consumer Privacy Bill of Rights, which is based on the FIPs and provides a comprehensive framework for consumer privacy, is the best baseline set of privacy protections for users and consumers. According to EPIC, the NITRD "should focus on technology that facilitates the implementation of the privacy protections listed in the CPBR." Earlier in 2014, EPIC submitted comments on "Big Data and the Future of Privacy" and has several times called for the end of opaque algorithmic profiling. The White House's subsequent report on Big Data and the Future of Privacy incorporated several recommendations from EPIC and other privacy organizations. EPIC: Comments to NITRD re: RFI (Oct. 17, 2014) NITRD: RFI - National Privacy Research Strategy (Sep. 18, 2014) The White House: Consumer Privacy Bill of Rights (Feb. 2012) The White House: Report on Big Data (May 1, 2014) EPIC: Petition to OSTP re: Big Data Public Comments (Feb. 10, 2014) EPIC: Comments on Big Data and the Future of Privacy (Apr. 4, 2014) EPIC: Big Data and the Future of Privacy ======================================================================== [4] EPIC, 49 Other Organizations Urge Obama to Update FOIA ========================================================================= EPIC and a coalition of transparency and open government advocates have written a letter to President Obama, urging him to update the Freedom of Information Act. "Only statutory reform and your public commitment to that reform will ensure the commitments you have made last beyond your presidency," the coalition wrote. In early 2009, President Obama signed a memorandum pledging an "unprecedented level of openness" in his Administration. According to the memo, the President sought to ensure trust and establish a system of transparency, public participation and collaboration. To that end, the President directed executive agencies to develop recommendations for implementing the president's open government goals. The President's promise of an exceptionally open and transparent government, wrote the coalition, continues to face numerous challenges. As a result, the coalition identified six core components it believes "at a minimum must be legislatively mandated in order to achieve your FOIA agenda." First, Congress must codify the presumption of disclosure in order to prevent reversal by future administrations. "Without this mandate," wrote the groups, "the FOIA will continue to be subject to the political whims of whoever occupies the White House." Second, Congress must also codify the foreseeable harm standard mandated by the current US Attorney General. Under this standard, records are only withheld where disclosure would cause a foreseeable harm to government interests. Third, government agencies must weigh the public interest when withholding inter- and intra-agency memoranda under the deliberative process privilege of FOIA exemption 5. This privilege, the coalition argued, "continues to be significantly overused, disserving the very interests your memorandum commits to advance." Fourth, information created 25 or more years before the date of a FOIA request should not be subject to FOIA exemption 5. "The FOIA should not be used to bar the public's access to our nation's history where the passage of time has significantly eroded, if not eliminated altogether, any valid governmental interest served by secrecy," wrote the groups. Fifth, Congress must amend the FOIA to prohibit agencies from charging fees once the agencies have missed statutory deadlines. Finally, Congress must enhance and expand the role of the Office of Government Information Services to reflect and ensure the office's role in streamlining the FOIA process and reducing FOIA litigation. EPIC frequently uses the FOIA to obtain government records on surveillance and privacy policy. In July 2014, EPIC filed a lawsuit against the Central Intelligence Agency to obtain final reports from the CIA's Inspector General on the agency's involvement in penetrating the US Senate Intelligence Committee's computer network. EPIC et al.: Letter to President Obama re: FOIA (Oct. 23, 2014) The White House: Memorandum on Transparency and Open Government EPIC: Open Government EPIC: FOIA Cases EPIC: EPIC v. CIA ========================================================================= [5] EPIC Spotlight: Domestic Drones, Surveillance and Privacy Risks ========================================================================= EPIC's "Spotlight on Surveillance" Project returns to focus attention on domestic drone surveillance. The 2012 FAA Modernization Act directed the Federal Aviation Administration to integrate drones into the National Airspace System, immediately raising concerns about both safety and privacy. The Act also required the agency to conduct a public rulemaking assessing public safety concerns, flight standards and licensing and air traffic requirements for drone use. In response to Congress's mandate to the FAA, EPIC, joined by over 100 other organizations, experts and members of the public, petitioned the agency to address privacy in the integration process. "Drones greatly increase the capacity for domestic surveillance," stated the petition. In February 2013, the Agency responded to EPIC's petition, announcing it would "address [privacy issues] through engagement and collaboration with the public." As a result, the FAA published a Notice with proposed privacy requirements for drone operators. EPIC's comments recommended that the FAA mandate the proposed privacy standards, which are based on the Fair Information Practices, and maintain a public database of all drone operators. EPIC has also testified before Congress in support of drone privacy law. Many drones have been outfitted with invasive surveillance equipment, including ultra-high definition cameras, thermal and infrared imaging and automated license plate readers. Domestic drone use has increased dramatically in recent years; law enforcement units in Florida, Texas and South Carolina have acquired drones for operational use. The US Bureau of Customs and Border Protection operates nine Predator drones along US borders. In late 2011, the Bureau found itself embroiled in controversy when it was reported that a drone was loaned to North Dakota law enforcement to locate missing livestock. Although the FAA has banned the commercial use of drones, the agency has begun granting limited exemptions. In 2014 the FAA granted exemptions to six movie and TV production companies. The agency is currently considering another 40 requests from various commercial entities, including Amazon, Google and Domino's Pizza. EPIC's Spotlight "Eyes in the Sky" examines the surveillance capabilities of drone technology and recommends comprehensive privacy legislation. US Congress: FAA Modernization Act of 2012 (Feb. 14, 2012) EPIC: Spotlight on Surveillance: "Eyes in the Sky" (Oct. 2014) FAA: Press Release: Exemptions for Commercial Drones (Sept. 25, 2014) EPIC et al.: Petition to FAA re: Drones (Feb. 24, 2012) EPIC: Letter from FAA Chief Counsel to EPIC (Feb. 14, 2013) EPIC: Comments to FAA on Drones and Privacy (Apr. 23, 2013) EPIC: Congressional Testimony on Drones (Mar. 20, 2013) ======================================================================== [6] News in Brief ======================================================================== Supreme Court to Rule on Privacy of Hotel Records The US Supreme Court has agreed to hear Los Angeles v. Patel, a challenge to a local ordinance that allows police to inspect hotel guest registries without a warrant or judicial supervision. A federal appeals court ruled in December 2013 that the LA law was "facially" unconstitutional because the authority could violate the Fourth Amendment. The Court will consider both the scope of privacy protections for hotel guests and whether the Fourth Amendment prohibits laws that allow unlawful searches. This second issue has far-reaching consequences because many recent laws authorize police searches without judicial review. To date, courts have only considered "as applied" challenges on a case-by-case basis. EPIC will likely file a "friend of the court" brief with the Supreme Court in support of the lower court's decision. US Supreme Court: Certiorari in Los Angeles v. Patel (Oct. 20, 2014) EPIC: Los Angeles v. Patel Ninth Circuit Court: Opinion in Los Angeles v. Patel (Dec. 24, 2013) EPIC: Amicus Curiae Briefs New Report Reviews Progress on Signals Intelligence Reform The Office of the Director of National Intelligence has released the first report on the implementation of Presidential Policy Directive 28. In January 2014, the President proposed a revised policy for foreign signals intelligence. Under the revised directive, PPD-28, intelligence agencies are required to "review and update" their policies and "establish new ones as necessary" to safeguard personal information collected through signals intelligence. Signals intelligence activities must also be "as tailored as feasible," and there must be limitations on the querying, use, dissemination and retention of personal information. The report states that all intelligence agencies must have PPD-28 in place by January 17, 2015, one year after the President's speech. In 2013, EPIC challenged the NSA's bulk collection of domestic and international call detail records. EPIC has also filed Freedom of Information Act requests with the NSA and other intelligence agencies, seeking disclosure of current procedures regarding surveillance conducted under Executive Order 12333. ODNI: "Safeguarding the Personal Information of All People" (July 2014) The White House: Press Release on PPD-28 (Jan. 17, 2014) The White House: Remarks on Signals Intelligence (Jan. 17, 2014) EPIC: In re EPIC (NSA) EPIC: FOIA Request to NSA re: EO 12333 (Jul. 31, 2014) EPIC: EO 12333 FCC Levies $10M Fine Against Carriers for Breach of Consumer Privacy The Federal Communications Commission has announced the agency's largest privacy fines to date. The FCC's first data security case stems from an investigation of mobile service carriers TerraCom and YourTel America, which "stored Social Security numbers, names, addresses, driver's licenses and other sensitive information belonging to their customers on unprotected Internet servers that anyone in the world could access." The carriers will be fined $10M for their breach of consumer privacy. This decision follows the FCC's $7.4M settlement with Verizon over privacy violations. In 2013, EPIC urged the FCC to determine whether Verizon violated the Communications Act when it released consumer call detail information to the National Security Agency. In 2007, in response to a 2005 EPIC petition, the FCC strengthened privacy protections for telephone records, which EPIC also defended in a "friend of the court" brief for the DC Circuit, ultimately establishing support for opt-in privacy safeguards. FCC: Press Release on Mobile Carrier Settlement (Oct. 24, 2014) FCC: Text of Verizon Settlement (Sep. 2, 2014) EPIC: Letter to FCC re: Verizon (Nov. 15, 2013) EPIC: Petition to FCC re: CPNI (Aug. 2005) FCC: Ruling on Telephone Record Privacy (Apr. 2, 2007) EPIC: "Friend of the Court" Brief in NCTA v. FCC (May 6, 2008) EPIC: NCTA v. FCC (Concerning Privacy of CPNI) In re EPIC (NSA Telephone Records Surveillance) Senator Rockefeller Questions Whisper About Privacy Practices Senator Jay Rockefeller (D-WV) has asked, an app and website where users can post anonymously, to answer several questions about the company's practices and policies. Whisper claims it does not track users and that it respects users' decisions to opt out of geolocational tracking. But newspaper The Guardian has revealed that Whisper tracks "the precise time and approximate location of all messages" and specifically tracks certain users the company deems "newsworthy." Senator Rockefeller, chair of the Senate Committee on Commerce has asked Whisper to explain its tracking, data retention and disclosure practices. EPIC has several similar matters pending before the Federal Trade Commission. Sen. Jay Rockefeller (D-WV): Letter to WhisperText (Oct. 22, 2014) The Guardian: "Revealed: how Whisper app tracks 'anonymous' users" (Oct. 6, 2014) app-tracking-users US Senate Commerce Committee EPIC: In re WhatsApp EPIC: Snapchat EPIC: FTC ======================================================================== [7] EPIC in the News ======================================================================== "EPIC: driver data shared via V2V technology needs protection." SC Magazine, Oct. 23, 2014. technology-needs-protection/article/379035/ "Big Data Research Effort Faces Student-Privacy Questions." GovTech, Oct. 23, 2014. Student-Privacy-Questions.html "FTC Snags Soltani for Chief Technologist Role." ECommerce Times, Oct. 22, 2014. "Your Car Won't Start. Did You Make The Loan Payment?" Montana Public Radio, Oct. 21, 2014. "Supreme Court to decide if cops can access hotel registries without warrants." Ars Technica, Oct. 21, 2014. if-cops-can-access-hotel-registries-without-warrants/ "Personalized Learning Pits Data Innovators Against Privacy Advocates." Education Week, Oct. 20, 2014. "Push for 'Learner Profiles' Stymied by Barriers." Education Week, Oct. 20, 2014. h34.html "Charlotte police investigators secretly track cellphones." Charlotte Observer, Oct. 18, 2014. police-investigators.html#.VEUXNYvF-1A "Privacy experts call for Whisper to be investigated over tracking of some users." The Guardian, Oct. 17, 2014. whisper-tracking-users "FBI head concerned over Apple and Google encryption." NPR's "Marketplace," Oct. 17, 2014. apple-and-google-encryption "A Look Behind the Snapchat Photo Leak Claims." The New York Times, Oct. 17, 2014. photo-leak-claims/ For More EPIC in the News: ======================================================================= [8] EPIC Bookstore ======================================================================= "Litigation Under the Federal Open Government Laws 2010," edited by Harry A. Hammitt, Marc Rotenberg, John A. Verdi, Ginger McCall, and Mark S. Zaid (EPIC 2010). Price: $75. Litigation Under the Federal Open Government Laws is the most comprehensive, authoritative discussion of the federal open access laws. This updated version includes new material regarding President Obama's 2009 memo on Open Government, Attorney General Holder's March 2009 memo on FOIA Guidance, and the new executive order on declassification. The standard reference work includes in-depth analysis of litigation under: the Freedom of Information Act, the Privacy Act, the Federal Advisory Committee Act, and the Government in the Sunshine Act. The fully updated 2010 volume is the 25th edition of the manual that lawyers, journalists and researchers have relied on for more than 25 years. ================================ "Information Privacy Law: Cases and Materials, Second Edition" Daniel J. Solove, Marc Rotenberg, and Paul Schwartz. (Aspen 2005). Price: $98. This clear, comprehensive introduction to the field of information privacy law allows instructors to enliven their teaching of fundamental concepts by addressing both enduring and emerging controversies. The Second Edition addresses numerous rapidly developing areas of privacy law, including: identity theft, government data mining and electronic surveillance law, the Foreign Intelligence Surveillance Act, intelligence sharing, RFID tags, GPS, spyware, web bugs, and more. Information Privacy Law, Second Edition, builds a cohesive foundation for an exciting course in this rapidly evolving area of law. ================================ "Privacy & Human Rights 2006: An International Survey of Privacy Laws and Developments" (EPIC 2007). Price: $75. This annual report by EPIC and Privacy International provides an overview of key privacy topics and reviews the state of privacy in over 75 countries around the world. The report outlines legal protections, new challenges, and important issues and events relating to privacy. Privacy & Human Rights 2006 is the most comprehensive report on privacy and data protection ever published. ================================ "The Public Voice WSIS Sourcebook: Perspectives on the World Summit on the Information Society" (EPIC 2004). Price: $40. This resource promotes a dialogue on the issues, the outcomes, and the process of the World Summit on the Information Society (WSIS). This reference guide provides the official UN documents, regional and issue-oriented perspectives, and recommendations and proposals for future action, as well as a useful list of resources and contacts for individuals and organizations that wish to become more involved in the WSIS process. ================================ "The Privacy Law Sourcebook 2004: United States Law, International Law, and Recent Developments," Marc Rotenberg, editor (EPIC 2005). Price: $40. The Privacy Law Sourcebook, which has been called the "Physician's Desk Reference" of the privacy world, is the leading resource for students, attorneys, researchers, and journalists interested in pursuing privacy law in the United States and around the world. It includes the full texts of major privacy laws and directives such as the Fair Credit Reporting Act, the Privacy Act, and the OECD Privacy Guidelines, as well as an up-to-date section on recent developments. New materials include the APEC Privacy Framework, the Video Voyeurism Prevention Act, and the CAN-SPAM Act. ================================ "Filters and Freedom 2.0: Free Speech Perspectives on Internet Content Controls" (EPIC 2001). Price: $20. A collection of essays, studies, and critiques of Internet content filtering. These papers are instrumental in explaining why filtering threatens free expression. ================================ EPIC publications and other books on privacy, open government, free expression, and constitutional values can be ordered at: EPIC Bookstore: ================================ EPIC also publishes EPIC FOIA Notes, which provides brief summaries of interesting documents obtained from government agencies under the Freedom of Information Act. Subscribe to EPIC FOIA Notes at: ======================================================================= [9] Upcoming Conferences and Events ======================================================================= "#FOIAat40." Speakers: EPIC President Marc Rotenberg and EPIC Administrative Law Counsel Khaliah Barnes. Washington, DC: Georgetown Law Center, October 30, 2014. For More Information: technology/events/index.cfm. Maine Judicial Conference. Speaker: EPIC Associate Director Ginger McCall. Rockport, ME: October 30-31, 2014. For More Information: "Bird's Eye View: Transatlantic Data Exposures and Regulatory Enforcement." Speaker: EPIC Associate Director Ginger McCall. Scottsdale, AZ: Privacy XChange Forum, November 3, 2014. For More Information: "FUSION: Rise Up." Speaker: EPIC President Marc Rotenberg. Washington, DC: November 19, 2014. For More Information: ======================================================================= Join EPIC on Facebook and Twitter ======================================================================= Join the Electronic Privacy Information Center on Facebook and Twitter: Start a discussion on privacy. Let us know your thoughts. Stay up to date with EPIC's events. Support EPIC. ======================================================================= Privacy Policy ======================================================================= The EPIC Alert mailing list is used only to mail the EPIC Alert and to send notices about EPIC activities. We do not sell, rent or share our mailing list. We also intend to challenge any subpoena or other legal process seeking access to our mailing list. We do not enhance (link to other databases) our mailing list or require your actual name. In the event you wish to subscribe or unsubscribe your e-mail address from this list, please follow the above instructions under "subscription information." ======================================================================= About EPIC ======================================================================= The Electronic Privacy Information Center is a public interest research center in Washington, DC. It was established in 1994 to focus public attention on emerging privacy issues such as the Clipper Chip, the Digital Telephony proposal, national ID cards, medical record privacy, and the collection and sale of personal information. EPIC publishes the EPIC Alert, pursues Freedom of Information Act litigation, and conducts policy research. For more information, see http://www.epic.orgor write EPIC, 1718 Connecticut Ave. NW, Suite 200, Washington, DC 20009. +1 202 483 1140 (tel), +1 202 483 1248 (fax). ======================================================================= Support EPIC ======================================================================= If you'd like to support the work of the Electronic Privacy Information Center, contributions are welcome and fully tax-deductible. Checks should be made out to "EPIC" and sent to 1718 Connecticut Ave. NW, Suite 200, Washington, DC 20009. Or you can contribute online at: Your contributions will help support Freedom of Information Act and First Amendment litigation, strong and effective advocacy for the right of privacy and efforts to oppose government and private-sector infringement on constitutional values. ======================================================================= Subscription Information ======================================================================= Subscribe/unsubscribe via web interface: Back issues are available at: The EPIC Alert displays best in a fixed-width font, such as Courier. ------------------------- END EPIC Alert 21.20------------------------

WorldLII: Copyright Policy | Disclaimers | Privacy Policy | Feedback